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#1719939 - 07/13/12 05:08 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Why not include such questions in a comment letter?
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RESPA
#1719974 - 07/13/12 05:54 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
#Just Jay Offline
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I am planning on writing my first comment letter ever, based on these proposals!

That, amongst other items, will surely be included.
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#1719998 - 07/13/12 06:22 PM Re: RESPA/Reg Z Proposal Is Out #Just Jay
MN Banker Offline
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Originally Posted By: Just Jay
I am planning on writing my first comment letter ever, based on these proposals!

That, amongst other items, will surely be included.


So am I!

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#1720027 - 07/13/12 07:23 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
ahou Offline
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ahou
Joined: Aug 2002
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You add the 2 CC that are 10% tol group together. If over 10%, you can use the revised disclosure. (at least that's how I read it)

ii. Assume a creditor receives information on Monday that, because of a changed circumstance under § 1026.19(e)(3)(iv)(A), the title fees will increase by an amount totaling six percent of the originally estimated settlement charges subject to § 1026.19(e)(3)(ii). The creditor had received information three weeks before that, because of a changed circumstance under § 1026.19(e)(3)(iv)(A), the appraisal fees increased by an amount totaling five percent of the originally estimated settlement charges subject to § 1026.19(e)(3)(ii). Thus, on Monday, the creditor has received sufficient information to establish a valid reason for revision and must provide revised disclosures reflecting the 11 percent increase by Thursday to comply with § 1026.19(e)(4)(i).
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#1720774 - 07/17/12 06:52 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
ahkcompliance Offline
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Midwest
I went on vacation and come back and find these new proposals! I think I would like to go back on vacation!

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#1726336 - 08/02/12 01:13 PM Re: RESPA/Reg Z Proposal Is Out ahkcompliance
Sinatra Fan Offline
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Anyone have an idea on how long it takes for a proposal to be published in the Federal Register? I keep checking for this one, but nothing's there.
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#1728075 - 08/07/12 03:26 PM Re: RESPA/Reg Z Proposal Is Out Sinatra Fan
Sewanee, CRCM Offline
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TN
If memory serves me correctly, it's usually been about 2 weeks in the past, which means these are past due.

Why am I not surprised?
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#1728331 - 08/07/12 08:57 PM Re: RESPA/Reg Z Proposal Is Out Sinatra Fan
Deena Offline
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Deena
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PA
John Burnett posted this in the Financial Reform Forum earlier today
Quote:
It appears that the Bureau's 1,099-page proposal to integrate RESPA and TILA disclosures will be published on August 23, a mere 15 days prior to the first of its two comment deadlines (September 7). So if you're waiting to see the small-print version that saves trees, your window for review will be really tight if you wish to comment on (1) the proposal to delay certain DFA disclosures, or (2) the revised APR calculation. The rest of the proposal has a November 6 comment deadline.
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#1728463 - 08/08/12 01:09 PM Re: RESPA/Reg Z Proposal Is Out Deena
Sewanee, CRCM Offline
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TN
From BOL today:

• Bureau sets publication dates for proposals
For those waiting for the “small-print” versions, the CFPB has scheduled the Federal Register publication dates for its two recently proposed mortgage loan rules amending Regulations X and Z.
o August 15, 2012: High-cost mortgage and homeownership counseling
o August 23, 2012: Integrated mortgage disclosures
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#1728472 - 08/08/12 01:19 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
ahou Offline
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ahou
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Under the proposed rule, the preamble states that failure to disclose homeowner's ins on the estimate is not in "good faith". Since this is an item that is not subject to tolerances, what are we suppose to do?
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#1728478 - 08/08/12 01:26 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
#Just Jay Offline
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Quote for it, like we have had to do for purchases since the GFE was revised two and a half years ago.
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#1728498 - 08/08/12 01:56 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
ahou Offline
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ahou
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I was talking about an inadvertent error.
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#1728826 - 08/08/12 06:30 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
ahkcompliance Offline
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Midwest
I have been going through the proposed rule and have a question on the new definition of finance charge/APR. I have read two articles that kind of contradict one another. Are the following items under the new proposed rules considered part of the finance charge/APR?

1026.4(c)
(7) Real-estate related fees. The following fees in a transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount:

(i) Fees for title examination, abstract of title, title insurance, property survey, and similar purposes.

(ii) Fees for preparing loan-related documents, such as deeds, mortgages, and reconveyance or settlement documents.

(iii) Notary and credit-report fees.

(iv) Property appraisal fees or fees for inspections to assess the value or condition of the property if the service is performed prior to closing, including fees related to pest-infestation or flood-hazard determinations.

(v) Amounts required to be paid into escrow or trustee accounts if the amounts would not otherwise be included in the finance charge.

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#1728884 - 08/08/12 07:20 PM Re: RESPA/Reg Z Proposal Is Out ahkcompliance
ahou Offline
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ahou
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The 4(c)(7) charges are finance chgs for closed-end cr but not for HELOCs. At least that's the way I understand it.
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#1728901 - 08/08/12 07:33 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
ahkcompliance Offline
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Midwest
That is what I thought as well.

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#1729368 - 08/09/12 06:28 PM Re: RESPA/Reg Z Proposal Is Out CalifDreamin
RR Joker Offline
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The Swamp
Agree.
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